System and method for centralized clearing of over the counter foreign exchange instruments

ABSTRACT

The disclosed systems and methods relate to allowing trading of over the counter (“OTC”) foreign exchange (“FX”) contracts on a centralized matching and clearing mechanism, such as that of the Chicago Mercantile Exchange&#39;s (“CME”&#39;s) futures exchange system (the “Exchange”). The disclosed systems and methods allow for anonymous transactions, centralized clearing, efficient settlement and the provision of risk management/credit screening mechanisms to lower risk, reduce transaction costs and improve the liquidity in the FX market place. In particular, the disclosed embodiments increase speed of execution facilitating growing demand for algorithmic trading, increased price transparency, lower cost of trading, customer to customer trading, and automated asset allocations, recurring trades as well as clearing and settlement efficiencies.

REFERENCE TO RELATED APPLICATIONS

This application is a continuation under 37 C.F.R. § 1.53(b) of U.S.patent application Ser. No. 11/590,540 filed Oct. 31, 2006 now U.S. Pat.No. ______, which claims the benefit of the filing date under 35 U.S.C.§ 119(e) of U.S. Provisional Application Ser. No. 60/738,246 filed Nov.18, 2005, all of which are hereby incorporated by reference in theirentirety and relied upon.

COPYRIGHT NOTICE

A portion of the disclosure of this patent document contains materialwhich is subject to copyright protection. The copyright owner has noobjection to the facsimile reproduction by anyone of the patent documentor the patent disclosure, as it appears in the Patent and TrademarkOffice patent file or records, but otherwise reserves all copyrightrights whatsoever.

BACKGROUND

Futures Exchanges, referred to herein also as an “Exchange”, such as theChicago Mercantile Exchange Inc. (CME), provide a marketplace wherefutures and options on futures are traded. Futures is a term used todesignate all contracts covering the purchase and sale of financialinstruments or physical commodities for future delivery on a commodityfutures exchange. A futures contract is a legally binding agreement tobuy or sell a commodity at a specified price at a predetermined futuretime. Each futures contract is standardized and specifies commodity,quality, quantity, delivery date and settlement. An option is the right,but not the obligation, to sell or buy the underlying instrument (inthis case, a futures contract) at a specified price within a specifiedtime.

The foreign exchange market is the largest and most liquid financialmarket in the world, representing more than $1.2 trillion worth oftransactions each day. Also known as forex or FX, currency tradingtypically involves the simultaneous purchase of one currency whileselling another currency. Currencies are typically traded in pairs, suchas U.S. dollar/Japanese yen (USD/JPY) or Euro/U.S. dollar (EUR/USD), orvia currency indexes, such as the CME$INDEX™.

In order to capitalize on the foreign exchange market, CME also offersFX futures products, i.e. futures contracts where the underlyingfinancial instrument is a foreign currency transaction, in addition tofutures products based on other commodities and financial instruments.However, FX futures are not the only mechanisms by which foreigncurrencies may be traded. For example, the FX interbank market is aglobal network of the world's banks with no centralized location fortrading. Much of the business is conducted over the-phone orelectronically bank-to-bank. The FX market is a 24-hour-per-day marketduring the FX business week. The day starts in Asia, extends over toEurope and then into the U.S. daytime trading hours. Currencies aretraded around the world, around the clock, from Monday morning (Sundayafternoon Chicago/New York time) in New Zealand/Asia to the close of thebusiness week on Friday afternoon in Chicago/New York.

Over the Counter (“OTC”) is the term often used to refer to currencytrading instruments which are not classified as a “futures” instrumentas defined above and not traded on a futures exchange such as CME, i.e.that which is not a futures contract is an OTC contract. Such OTCcontracts include “forward” contracts, i.e. private agreements betweenbuyers and sellers, i.e. bilateral contracts, for the future delivery ofa commodity at an agreed price. While futures contracts are regulated bythe Commodity Futures Trading Commission (“CFTC”), forward or OTCcontracts are not so regulated, making them more flexible and anattractive device to certain investors and certain markets.

Speculators are active in the FX markets, as they are attracted to theopportunities that volatile and changing market conditions create. Amultitude of economic forces impact the world's currencies. Some of theforces at work include interest rate differentials, domestic moneysupply growth, comparative rates of inflation, central bank interventionand political stability. In times of global uncertainty, some currenciesmay benefit from perceived “flight-to-safety” status. Or, if onecountry's economic outlook is perceived as strong by market forces, itscurrency may be firmer than another country's currency, where economicor political conditions are viewed with caution.

FX traders include governments, corporations and fund managers doingbusiness with foreign countries, that need to exchange one currency foranother, and speculators who seek to profit from price movements in themarkets.

The highly liquid and volatile currency markets offer opportunities forspeculators every day. Most speculators tend to focus on the so-called“majors,” which are the most actively traded currencies and include theU.S. dollar, the euro, the Japanese yen, the British pound, the Swissfranc, the Australian dollar and the Canadian dollar.

While the OTC FX market offers advantages such as less regulation andmore product flexibility, CME's futures exchange offers its ownbenefits, such as centralized and anonymous matching and clearing, aswell as efficiency optimization and risk management/credit screeningmechanisms not available in the present OTC markets. It would thereforebe advantageous to be able to trade OTC FX products via the samemechanisms used to trade futures contracts in order to secure these samebenefits and protections.

Accordingly, there is a need for systems and methods to allow OTC FXproducts to be traded in a centralized matching and clearing environmentsuch as the environment utilized by CME's futures exchange.

BRIEF DESCRIPTION OF THE DRAWINGS

FIG. 1 depicts a block diagram of an exemplary system for trading OTC FXinstruments according to the disclosed embodiments.

FIG. 2A shows a more detailed block diagram of the system of FIG. 1according to one embodiment.

FIG. 2B shows a more detailed block diagram of the system of FIG. 1according to an alternative embodiment.

FIG. 3 shows an exemplary screen display and price determination.

FIG. 4 shows an exemplary business message flow for the Directed RFQfunctionality for use with the disclosed embodiments.

FIGS. 5A-5G depict block diagrams of a Flexible Hybrid CentralCounter-party Cross-Margining or Cross Collateralization systemaccording to one embodiment.

FIG. 6 depicts a more detailed block diagram of the system of FIG. 1according to one embodiment.

FIG. 7 depicts flow charts showing the operations of the system of FIGS.1 and 6 according to one embodiment.

DETAILED DESCRIPTION OF THE DRAWINGS AND PRESENTLY PREFERRED EMBODIMENTS

The disclosed systems and methods relate to allowing trading of over thecounter (“OTC”) foreign exchange (“FX”) contracts on a centralizedmatching and clearing mechanism, such as that of the Chicago MercantileExchange's (“CME”'s) futures exchange system (the “Exchange”). Thedisclosed systems and methods allow for anonymous transactions,centralized clearing, efficient settlement and the provision of riskmanagement/credit screening mechanisms to lower risk, reduce transactioncosts and improve the liquidity in the FX market place. In particular,the disclosed embodiments increase speed of execution facilitatinggrowing demand for algorithmic trading, increased price transparency,lower cost of trading, customer to customer trading, and automated assetallocations, recurring trades as well as clearing and settlementefficiencies.

FIG. 1 shows a block diagram of an exemplary system 100 for trading OTCFX instruments according to the disclosed embodiments. The system 100 isessentially a network 102 coupling market participants 104 106,including traders 104 and market makers 106 with the Exchange 108.Herein, the phrase “coupled with” is defined to mean directly connectedto or indirectly connected through one or more intermediate components.Such intermediate components may include both hardware and softwarebased components. Further, to clarify the use in the pending claims andto hereby provide notice to the public, the phrases “at least one of<A>, <B>, . . . and <N>” or “at least one of <A>, <B>, . . . <N>, orcombinations thereof” are defined by the Applicant in the broadestsense, superseding any other implied definitions herebefore orhereinafter unless expressly asserted by the Applicant to the contrary,to mean one or more elements selected from the group comprising A, B, .. . and N, that is to say, any combination of one or more of theelements A, B, . . . or N including any one element alone or incombination with one or more of the other elements which may alsoinclude, in combination, additional elements not listed. The Exchange108 provides the functions of matching 110 buy/sell transactions,clearing 112 those transactions, settling 114 those transactions andmanaging risk 116 among the market participants 104 106 and between themarket participants and the Exchange 108, as well as request-for-quotefunctionality 118, as is discussed in more detail below. FIGS. 2A and 2Bshow more detailed block diagrams of the logical architecture of thesystem 100 of FIG. 1. In particular, FIG. 2A shows a block diagram ofthe system 100 according to one embodiment in which the Exchange 108 isinterconnected with a second FX marketplace to allow existing FX marketparticipants to transact over the Exchange as described herein. In thisembodiment, the second FX marketplace is provided by Reuters. FIG. 2Bshows a block diagram of the system 100 according to a second embodimentin which the Exchange 108 further provides connectivity to existing FXmarket participants.

While the disclosed embodiments relate to the trading of OTC FXinstruments, the mechanisms and methods described herein are not limitedthereto and may be applied to any OTC product.

Typically, the Exchange 108 provides a “clearing house” which is adivision of the Exchange 108 through which all trades made must beconfirmed, matched and settled each day until offset or delivered. Theclearing house is an adjunct to the Exchange 108 responsible forsettling trading accounts, clearing trades, collecting and maintainingperformance bond funds, regulating delivery and reporting trading data.Essentially mitigating credit. Clearing is the procedure through whichthe Clearing House becomes buyer to each seller of a futures contract,and seller to each buyer, also referred to as a “novation,” and assumesresponsibility for protecting buyers and sellers from financial loss byassuring performance on each contract. This is effected through theclearing process, whereby transactions are matched. A clearing member isa firm qualified to clear trades through the Clearing House. In the caseof the CME's clearing house, all clearing members not specificallydesignated as Class B members are considered Class A clearing members.In the CME there are three categories of clearing members: 1) CMEclearing members, qualified to clear transactions for all commodities;2) IMM clearing members, qualified to clear trades for only IMM and IOMcommodities; and 3) IMM Class B clearing members, solely limited toconducting proprietary arbitrage in foreign currencies between a singleExchange-approved bank and the IMM and who must be guaranteed by one ormore Class A non-bank CME or IMM clearing member(s). Note that a“member” is a broker/trader registered with the Exchange. As will bediscussed below, in the disclosed embodiments, a new clearing memberclass may be introduced for the purposes of trading OTC FX, exclusivelyor along with other CME products, i.e. futures, as described herein. Itwill be appreciated that such classifications are implementationdependent.

In the presently disclosed embodiments, the Exchange 108 assumes anadditional role as the central intermediary in OTC FX transactions,i.e., the Exchange 108 will become the buyer to each seller and sellerto each buyer, and assume responsibility for protecting buyers andsellers from financial loss by assuring performance on each contract, asis done in futures transactions. As used herein, the term “Exchange” 108will refer to the centralized clearing and settlement mechanisms, riskmanagement systems, etc., as described below, used for futures trading,including the described enhancements to facilitate OTC FX transactions.By assuming this intermediary role and employing credit screening andrisk management mechanisms, parties previously not able to trade OTC FX,because for example they were credit screened out, may now tradeanonymously. In prior OTC FX markets, banks were the only sell-side totransactions. The presently disclosed embodiments permit traders to takeeither sell or buy-side positions and sell-side is no longer limited tobanks.

While the disclosed embodiments will be described in reference to theCME, it will be appreciated that these embodiments are applicable to anyExchange 108, including those which trade in equities and othersecurities. The CME Clearing House clears, settles and guarantees allmatched transactions in CME contracts occurring through its facilities.In addition, the CME Clearing House establishes and monitors financialrequirements for clearing members and conveys certain clearingprivileges in conjunction with the relevant exchange markets.

As an intermediary, the Exchange 108 bears a certain amount of risk ineach transaction that takes place. To that end, risk managementmechanisms protect the Exchange via the Clearing House. The ClearingHouse establishes clearing level performance bonds (margins) for all CMEproducts and establishes minimum performance bond requirements forcustomers of CME products. A performance bond, also referred to as amargin, is the funds that must be deposited by a customer with his orher broker, by a broker with a clearing member or by a clearing memberwith the Clearing House, for the purpose of insuring the broker orClearing House against loss on open futures or options contracts. Thisis not a part payment on a purchase. The performance bond helps toensure the financial integrity of brokers, clearing members and theExchange as a whole. The Performance Bond to Clearing House refers tothe minimum dollar deposit which is required by the Clearing House fromclearing members in accordance with their positions. Maintenance, ormaintenance margin, refers to a sum, usually smaller than the initialperformance bond, which must remain on deposit in the customer's accountfor any position at all times. The initial margin is the total amount ofmargin per contract required by the broker when a futures position isopened. A drop in funds below this level requires a deposit back to theinitial margin levels, i.e. a performance bond call. If a customer'sequity in any futures position drops to or under the maintenance levelbecause of adverse price action, the broker must issue a performancebond/margin call to restore the customer's equity. A performance bondcall, also referred to as a margin call, is a demand for additionalfunds to bring the customer's account back up to the initial performancebond level whenever adverse price movements cause the account to gobelow the maintenance. As will be discussed below, additionalfunctionality is provided in the disclosed embodiments to provide riskmanagement for OTC FX transactions.

The accounts of individual members, clearing firms and non-membercustomers doing business through CME must be carried and guaranteed tothe Clearing House by a clearing member. As mentioned above, in everymatched transaction executed through the Exchange's facilities, theClearing House is substituted as the buyer to the seller and the sellerto the buyer, with a clearing member assuming the opposite side of eachtransaction. The Clearing House is an operating division of the Exchange108, and all rights, obligations and/or liabilities of the ClearingHouse are rights, obligations and/or liabilities of CME. Clearingmembers assume full financial and performance responsibility for alltransactions executed through them and all positions they carry. TheClearing House, dealing exclusively with clearing members, holds eachclearing member accountable for every position it carries regardless ofwhether the position is being carried for the account of an individualmember, for the account of a non-member customer, or for the clearingmember's own account. Conversely, as the contra-side to every position,the Clearing House is held accountable to the clearing members for thenet settlement from all transactions on which it has been substituted asprovided in the Rules. As will be explained below, these mechanisms willbe augmented so as to handle OTC FX transactions.

More information about minimizing the risk to the Exchange 108 whilesimilarly minimizing the burden on members, approximating the requisiteperformance bond or margin requirement as closely as possible to theactual positions of the account at any given time and improving theaccuracy and flexibility of the mechanisms which estimate performancebond requirements, may be found in the following U.S. patentapplications, all of which are incorporated by reference herein:

-   U.S. patent application Ser. No. 11/030,815, “SYSTEM AND METHOD FOR    ACTIVITY BASED MARGINING”, filed Jan. 7, 2005, now U.S. Pat. No.    7,769,667;-   U.S. patent application Ser. No. 11/030,796, “SYSTEM AND METHOD FOR    EFFICIENTLY USING COLLATERAL FOR RISK OFFSET”, filed Jan. 7, 2005,    now U.S. Pat. No. 7,426,487;-   U.S. patent application Ser. No. 11/030,833, “SYSTEM AND METHOD FOR    ASYMMETRIC OFFSETS IN A RISK MANAGEMENT SYSTEM”, filed Jan. 7, 2005,    now U.S. Pat. No. 7,509,275;-   U.S. patent application Ser. No. 11/030,814, “SYSTEM AND METHOD FOR    DISPLAYING A COMBINED TRADING AND RISK MANAGEMENT GUI DISPLAY”,    filed Jan. 7, 2005, now U.S. Pat. No. 8,849,711;-   U.S. patent application Ser. No. 11/031,182, “SYSTEM AND METHOD FOR    FLEXIBLE SPREAD PARTICIPATION”, filed Jan. 7, 2005, now U.S. Pat.    No. 7,593,877;-   U.S. patent application Ser. No. 11/030,869, “SYSTEM AND METHOD FOR    HYBRID SPREADING FOR RISK MANAGEMENT”, filed Jan. 7, 2005, now U.S.    Pat. No. 7,428,508; and-   U.S. patent application Ser. No. 11/030,849, “SYSTEM AND METHOD OF    MARGINING FIXED PAYOFF PRODUCTS”, filed Jan. 7, 2005, now U.S. Pat.    No. 7,430,539.

In the present OTC FX markets, liquidity and access to pricing isfragmented creating inefficiencies for market participants. Suchfragmentation is due in part to traditional reliance on bi-lateralcounterpart credit that compartmentalizes trading, as well as the legacyrole of banks as market makers to non-bank traders/firm. The centrallycleared marketplace for OTC FX provided by the disclosed embodimentspermits access to the best pricing, equal access for all marketsegments, and buy-side and sell-side, as well as operationalefficiencies, as will be discussed.

In bi-lateral trading, buyers and sellers essentially consummate dealson their own. Sellers must accept each buyer's credit, buyers sendpayment directly to each seller and buyers must accept each seller'sability to perform on the contract. If either party wishes to close outa deal prior to delivery, they must negotiate exclusively with theiroriginal counterparty. Such bi-lateral trading creates inefficienciesfor the FX buy-side. For example, bi-lateral trading creates inefficientpricing in that the market consists of multiple trading counterpartiesand the requirement to open and close positions with the same bank.Further, bi-lateral trading creates inefficient use of collateral, e.g.there may be requirements to place margin at several banks, and createsexcessive operational risk, e.g. multiple back-office confirmationrelationships.

Present FX trade settlement utilizes the Continuous Linked Settlement(“CLS”) Bank. Prior to the availability of the CLS Bank, FX tradesettlements resulted in separate currency payments between tradecounterparties, which incurred heightened risk that one party mightdefault, especially in view of time zone differences, also known as“Herstaat Risk.” The CLS Bank eliminates ‘temporal’ settlement risk bysettling both sides of dual currency payments by delivery-vs.-payment,thereby mitigating Herstaat Risk in daily settlements.

Straight-Through-Processing (“STP”) provides the benefits of reductionin errors during processing, acceleration of trade processing, real timerisk management, automated account allocations, and back office staffingefficiencies. However, in the present OTC FX markets, the benefits ofSTP are limited by lack of standardization and real time delivery ofboth electronic trade affirmations and trade confirmations.

The disclosed embodiments offer reduced cost of market access, andthereby better access to best-pricing, lower infrastructure supportcosts and easier and less costly trade execution, price and volumetransparency, efficient risk transfer, STP standardization and auditableprices and mark-to-market.

In particular, the disclosed embodiments feature centralized OTC FXexecution and clearing via a centralized matching and clearing platformaccessed, for example, via prime brokers/direct clearing. The disclosedsystems and methods may be used by institutional participants in the OTCFX markets, such as banks, asset managers, leveraged trading firms(hedge funds, CTA's, prop firms, etc.), and/or currency program andoverlay managers. The disclosed systems and methods may support OTC FXproducts, such as Spot, FX forward swap and FX options instruments. Thedisclosed systems and methods utilize trade matching technology as wellas graphic user interface (“GUI”) and application program interface(“API”) based methods of interaction. Further, a novel request for quoteprocess is provided. In the disclosed embodiments, clearing takes placevia the Exchange clearing house, such as the CME Clearing House. Dailysettlements may still occur utilizing the CLS bank but with addedefficiencies which will be discussed below. Collateralized riskmargining is also provided as will be discussed below. Further, OTC STPprotocols are supported.

The disclosed embodiments provide value for the buy-side of OTC FXtransactions. In particular, the disclosed systems and methods addresscustomer demand for increased FX market efficiencies, pre-trade, tradeand post-trade. For example, the disclosed embodiments provide access totrading lines and limits as well as audited and published FX price andvolume data. Further, access to best pricing is provided as well astrade anonymity, improved execution speed, access to a primary liquiditypool, and access to multiple FX products. In addition, real time STP isprovided as is efficient trade/position management via multi-lateralnetting. Further all trading styles are accommodated, such asalgorithmic trading, GUI/Keyboard trading and request for quote (“RFQ”)based trading.

On the sell-side, the disclosed embodiments further provide value tobanks. For example, they permit the ability to extend market makingactivities beyond the limits of bilateral credit relationships, e.g.trade with new customers, extend trading with existing customers, etc.Further, increased access to FX liquidity and accommodation of varioustrading styles is also provided. In addition, access to real time riskmanagement and STP is provided along with credit and settlement riskmitigation.

In at least one of the disclosed embodiments, a hybrid market model maybe provided which combines exchange central limit order book matchingand bilateral trading of the OTC market with expanded electronic,anonymous access and clearing. Alternatively, other embodiments mayprovide sub-sets of this functionality.

The disclosed embodiments support one or more of the following FXinstrument types: forwards, spot and swaps. Forwards refers to FXforward contracts that expire daily starting from tomorrow, i.e. the dayafter the transaction date, and running out for two years, for eachcurrency-pair. A “Spot” refers the Forward which expires in two daysafter the transaction date. A swap is essentially a calendar spread,i.e. the simultaneous purchase (sale) of contract(s) in a near deliverymonth (first leg) and the sale (purchase) of an equal number ofcontract(s) in a far delivery month of the same contract (second leg),where the first leg is a Spot and the second leg is a further outForward.

In one embodiment, a defined number of swap products are offeredincluding Spot against the following (37 in total, assuming it thestated day or next day thereafter which is not a holiday in eithercurrency):

-   -   Tomorrow—Tom Next (TIN)¬—The Swap which has a first Forward leg        expiring tomorrow and the next Forward leg as “Spot”    -   The day after tomorrow—Spot Next (S/N)    -   Swap Forwards at 1 week, 2 weeks, 3 weeks    -   Monthly Swap Forwards from 1 month through 24 months    -   Except if this date is on a weekend or a holiday in either        currency, go to the first preceding week date which is not a        holiday in either currency    -   Except if the spot value date is the last date of the month,        then go to the last week date of the N'th month following which        is not a holiday in either currency.    -   Swap Forwards at the 8 IMM dates over the next 2 years    -   Broken-Dated Swap—Any Swap which is not one of the pre-defined        Swaps above.

It will be appreciated that other product combinations may also beoffered.

Further, the disclosed embodiments utilize Daily Rolling Instrumentswherein the contract symbol used by the customers to reference a givenSwap or Spot does not change, day-to-day, but the Swap legs do changeeach day, i.e. the temporal references within the instrument are treatedas relative to the transaction date rather than being expressed inabsolute form thereby necessitating a significantly increased symbol setto reference them:

From the trader perspective, contract symbols for electronically matchedinstruments are “generic”—Fill messages include the value dates andprices of each leg;

Instrument definitions would therefore include contract symbols like“USDSPYSP” for Spot and “USDJPY1M” to specify the 1 month, forward Swap.

Each day, new instruments are used:

-   -   Forward for the 2 year date    -   All Swap instruments are refreshed with new legs

The appropriate value dates for electronically matched contracts areassigned by the system at match time and provided to the user within theorder entry/front office fill messages for each leg. For DirectedRequest For Quote (“Directed RFQ” or “DRFQ”), discussed in more detailbelow, users may enter the desired legs for a Directed RFQ using genericcontracts, with the requested value dates. For example, a user wishingto do an RFQ for a forward outright, i.e. an order to buy or sell onlyone specific type of contract, with a specific value date should be ableto specify that, without having to specify a unique contract that isassociated internally with that value date.

Referring to FIG. 3, in one embodiment, the Spot leg price is themid-point between the bid/ask in the current Spot market or last tradedwithin a specific time period; the other Forward leg price is made basedon the Spot price plus the differential (e.g. “30” is a 0.0030differential between the Spot and the Forward leg).

If the mid-point between the bid/ask in the current Spot market isstale, settlement information may be used. If the spot market is notliquid and no market data is currently being produced, customers will bekept up to date with secondary sources to minimize unexpected resultswhen the leg price comes in. A business rule of having the Spot marketsregularly quoted by market makers may provided.

For some markets, the Swap does not use the Spot for that market, butrather an associated market. This is accomplished by doing a reciprocal(1/current-price) calculation of the spot, or spot mid-point in thatassociated market.

In the disclosed embodiments, for the purposes of determining the valuedate, value date conventions are employed. For example, the value-dateconvention for spot for USD/CAD is one business day and for all othersit is two business days. A value date is valid for a currency pair if itis a banking business day for both currencies of the pair. Trading mayphysically occur on any weekday. However, for trading occurring on anygiven weekday, the rule for taking holidays into account whendetermining the value date for “spot” trading on that weekday differsdepending on the currency in which the holiday occurs. For holidays inUSD, you need only one full working day before you can settle a spottrade. For example: Wednesday July 4th (US Independence Day), a USDholiday; Monday's spot trading in USD/JPY has value date Thursday(because Wednesday is a USD holiday); Tuesday's spot trading in USD/JPYalso has value date Thursday (because you only need one USD workingday). For holidays in currencies other than USD, two full working daysbefore settlement may be required. For example: Wednesday December 7th(Pearl Harbor Day), a JPY holiday; Monday's spot trading in USD/JPY hasvalue date Thursday (because Wednesday is a JPY holiday); Tuesday's spottrading in USD/JPY has value date Friday (because Wednesday is a JPYholiday and you need two full working days in JPY).

In the disclosed embodiments, support for the instruments listed inTable 1 is provided. It will be appreciated that the instrumentofferings may vary and are implementation dependent. In particular, theCentral Limit Order Book (“CLOB”) will support Spot and/or standardizedSwap forwards. The Directed RFQ mechanism, discussed in more detailbelow, will support Spot, Forwards (any date out to 2 years), Swapforwards (standardized cases), Broken-dated swaps, or combinationsthereof.

TABLE 1 Spot Swaps Number Number Spot Swap Tradable Tradable ContractsContracts Trading Trading via via via Including Currency Pair ShorthandQuoted In Unit Unit CLOB CLOB CLOB Forwards Euro - EUR/USD USD EUR USD xx 38 541 USD USD - USD/JPY JPY USD USD x x 38 541 Japanese Yen BritishGBP/USD USD GBP USD x x 38 541 Pound - USD Australian AUD/USD USD AUDUSD x x 38 541 Dollar - USD USD - USD/CHF CHF USD USD x x 38 541 SwissFranc USD - USD/CAD CAD USD USD x x 38 541 Canadian Dollar Euro -EUR/JPY JPY EUR x 1 504 Japanese Yen Euro - EUR/GBP GBP EUR x 1 504British Pound Euro - EUR/CHF CHF EUR x 1 504 Swiss Franc British GBP/JPYJPY GBP x 1 504 Pound - Japanese Yen Japanese JPY/USD USD JPY x 37 541Yen - USD Swiss CHF/USD USD CHF x 37 541 Franc - USD Canadian CAD/USDUSD CAD x 37 541 Dollar - USD total 343 6885 * Swaps are not listed forthe non-USD currency pairs.

In disclosed embodiments, three currency-pairs will have a secondarymarket for the alternate listing (e.g. a W$ contract and a $/k contractwill both exist, as completely separate markets):

-   -   Japanese Yen    -   Swiss Franc    -   Canadian Dollar        Forward outright instruments will be quoted in terms of one        currency only (e.g. a $/¥        Forward is quoted in JPY, not USD). Swap instruments will be        quoted in differential.

In the disclosed embodiments, there are 10 currency pairs, but only 6with swaps defined. Contract sizes will be 1 million units of the basecurrency. Instruments tick in tenths, not quarters nor in a variabletick table (VTT).

With regard to daily value date roll-over, users need only be notifiedthat the value date has changed for the Spot and Swaps, rather than whatthe change is for each instrument. In one embodiment, users are notifiedas to what the current value dates are for each instrument. Participantscan request value dates for each instrument from the marketplace.

A new flag on the Instrument Definition market data message is provided(the MO, em-oh) which is available for use in this market. One exampleusage could be in the situation where each instrument was listedindividually. This flag could change daily for many of theseinstruments, as indicated by the “Tradable” flags in the table above.

In one embodiment, any of the listed forwards, while not on a centrallimit order book, may be traded via the Directed RFQ system (notedbelow). Traders may also use the Directed RFQ system to dynamicallycreate a Broken-dated Swap market consisting of those Swaps notpre-defined (i.e. those which have a non-standard forward leg). Thesemarkets are also not on a central limit order book.

It will be appreciated that the foregoing instrument definitions andconventions are implementation dependent and suitable modifications toaccommodate alternative instruments and conventions are contemplatedherein. For example, while it is advantageous to utilize existingproduct symbology and instrument standards in the FX market place today,other symbology or standards, now available or later developed, may alsobe used with the disclosed systems and methods.

To facilitate clearing of OTC FX products using the clearing andsettlement mechanism, the disclosed embodiments feature a new class ofclearing member for banks and prime brokers addition to existingClearing house members. Existing Exchange membership may be used totrade on this new market as well. Further, for the disclosedembodiments, only Institutional users will be permitted to use theplatform (no retail). Clearing firms will have to guarantee that theircustomers meet the established criteria for access. These criteria maybe based on capitalization. The same single risk pool will be used forthe safeguard system. In alternative embodiments, the marketparticipants may be defined differently.

With regard to market access, authorization may be required before orderentry can occur. Authorization should occur at the SubscriberAlias(originating location of the order) as well as the TraderID (orderoriginator) and/or Account (entity on behalf of which the order is beingsubmitted) level of granularity but may effect the registration process.In one embodiment, authorization occurs by TraderID and/or Account. Inone embodiment authorization is for the entire market rather thangranular to currency pair

The application of a central counterparty to OTC FX transactions permitsadditional functionality to be offered to OTC FX market participants. Inone embodiment, netting is provided which allows various FX positions tobe netted together for settlement rather than separately settled,thereby reducing the number of settlement transactions and theassociated transaction costs. The individual transactions are stilltracked and reported but the actual number of settlement transactions,for example, those sent to CLS, is reduced. In another embodiment,collateralization is provided which allows the value of an entity's FXaccount, which may change in value via debits and credits but not basedon the actual movement of value, to be used against that entity's marginrequirement of their futures trading account, thereby simplifying marginrequirements and reducing the overall burden.

In one embodiment, as shown in FIG. 2A, CME provides clearing andsettlement functionality while a separate market, such as Reuters,provides matching functionality and access to sell-side entities, suchas banks. In an alternate embodiment, as shown in FIG. 2B, CME providesmatching, clearing and settlement functionality. It will be appreciatedthat the division of functionality for in-taking, processing andcompleting a given transaction is implementation dependent.

In order to implement OTC FX within the clearing and settlementmechanisms of the Exchange, additional market functionality is needed,such as: match engine functionality; surveillance, market control andregistration functionality; RFQ functionality; market datafunctionality; trade data functionality; clearing/tradereporting/straight-through-processing (“STP”) functionality; feefunctionality; and front-end/distribution functionality.

In particular, the match engine matches up sell-side and buy-side ordersto complete trades. In one embodiment, the match engine utilizes afirst-in-first-out (“FIFO”) matching algorithm for Spot transactions anda FIFO with Lead Market Maker matching algorithm for Forward Swaptransactions. In this embodiment, simple market maker protection isprovided for Forward Swap transactions. Mass quoting is also permittedwith Forward Swap transactions.

In one embodiment, specific features are provided for forward swapmarkets. In particular, approximately 10 to 20 Market Makers aretargeted for the forward Swap markets, across all markets. Leg pricingfor swaps is done on a differential basis, given the derived spot priceand the swap differential.

In one embodiment, the allocation will respect the 1 million currencybase unit contract size (i.e. products trade in base units of 1million). The match engine is not required to have credit controls noris it required to track the position of traders. Traders must know thedelivery/value dates of all leg fills. This can be accomplished eithervia the fill notification, a daily instrument creation market datamessage, or some other standardized electronic means.

Traders need to get leg fill notifications with prices immediately aftera match. Accordingly, order entry leg messages back to the trader forforward swaps should reflect one Spot leg, with its associated valuedate, and a generic forward leg, with its associated value date. This istrue regardless of whether the messages are generated as the result ofan electronic match, or a Directed RFQ-based block trade. Further, orderentry leg messages back to the trader for Spot contracts should reflectthe generic Spot contract and its associated value date, regardless ofwhether the messages are generated as the result of an electronic match,or an Directed RFQ block trade. In addition, order entry leg messagesback to the trader for forward out-rights should reflect the genericforward outright, and it's associated value date. Note that suchmessages can only be the result of an execution from a Directed RFQblock trade, since forward out-rights will not be electronicallymatched.

The Trading Engine must produce information on a trade as to whether agiven side was the aggressor order (i.e. the non-resting order). This isfor the purposes of the fee functionality, discussed below.

Implied functionality, as discussed in more detail below, may also beprovided.

The matching engine may support one or more of the following ordertypes, or combinations thereof:

-   -   Fill and Kill (“FAK”) & Limit orders;    -   RFQ for quantity will be available for those markets which are        traded in a central limit order book;    -   Stop Orders and Stop Price Logic;    -   Good Til Cancel (“GTC”) order types;    -   Good Til Day (“GTD”) order types;    -   Block trades;

The match engine may also provide consolidated fill reporting(front-office, back-office, and market data)

The Match Event/Trade Report to Clearing may need to include informationabout the entire spread. This will require either using the D1 message(as well as the M1) from the Match Engine to Clearing, or a newinterface/message altogether. See the Section below onClearing/Settlement for more information.

In one embodiment, the market will operate in continuous trading allweek (24 hours×5.5 days), with existing trade date rollover daily:

-   -   Markets open at 11:45 AM Chicago time on Sunday for a Monday        trade date. There may be no trade date rollover at 4:00 PM on        Sunday;    -   Markets close weekly at 4:00 PM on Friday;    -   There is no maintenance window from 4:00 PM to 5:00 PM. There        may be no IOP-like opening state;    -   The cutoff to the next trading day occurs at 4 PM Chicago time        (5 pm New York time);    -   Markets are open on most normal holidays;    -   All orders remain on book. On trade date rollover the legs of        that Swap are redefined (perhaps as an entirely new market, but        with the same External ID/Contract Symbol); and    -   If there is open interest in a Swap or Spot market on trade date        rollover, the orders remain actionable in that “generic” market,        but if traded will have new leg forward instruments.

The Surveillance, Market Control & Registration functionality providesaudit, security and authentication services. In one embodiment, ordermanagement tools are provided such as CME's FirmSoft, which is abrowser-based order management tool that provides real-time visibilityinto working and filled orders, across multiple firm IDs, in the CME®Globex® Order Management database. Accessible through the CME portal(via the internet) or through a production connection to the CME Globexplatform, CME FirmSoft provides important alternative access to workingand filled orders during system failures

Globex Control Center (“GCC”) must have current capabilities providedwith Eagle/Ghost for Market Surveillance

a. Status/Cancel Working Ordersb. Status Mass Quotesc. Status/Bust Tradesd. Status Blockse. Plus:

-   -   1. Surveillance by value-date    -   2. Agent shall use single Ghost instance to be able to perform        status across FX Marketplace and other CME markets    -   3. Status on Directed RFQ requests and responses can be done in        the same way as RFQ's are currently, but with information on        both parties available    -   4. Differences in terms & convention between the end trader &        GCC need to be taken into account for all tools (generic        instruments, value dates, etc)

The system may make available the following audit reports

-   -   Order & trade activity—overall and per market    -   Directed RFQ request and response activity—overall and per        market    -   A given Market Maker's activity in the above

The Exchange will control the account numbers that are authorized inthis market and for or each new participant, a unique account number iscreated

The set of registration data that should be collected for thismarketplace is similar to existing data for other markets:

1. First Name 2. Last Name 3. Date of Birth 4. Social Security # 5. WorkPhone

6. Work fax (mandatory)7. Email (mandatory)

8. Mobile Phone

9. City of birth

10. Secondary School

11. Trader ID(s) authorized12. Account #s (new addition but see below already part of TeleStat)13. Interfaces useda. iLink 2b. EOSc. Globex traderd. Firmsofte. FX Marketplace14. Contact typea. Technicalb. Marketc. Firm Admin Primaryd. Firm Admin Secondary

15. TeleStat

a. Security Questionb. Security Answerc. Trading Addressi. Cityii. Countryiii. Stated. Tag 50/Sender Sub IDe. Firm and Account # Combinations

16. Authorized Contact Signature 17. Clearing Firm Representation andAgreement

a. Name of clearing firmb. signature of officerc. name of officerd. titlee. date

18. Customer Representation and Agreement

a. name of customerb. signature of officerc. printed name of officerd. titlee. date

The FX Marketplace may require an error trade policy that will beadministered by the Globex Control Center (“GCC”). Existing error tradetools may be used. GCC should have current capabilities provided by ETPplus, as information about the spread will be passed to clearing, theETP system should allow inquiry based on this criteria

The Clearing House will provide each day the most economicallyappropriate end of day settlement prices need to be determined for opencontracts, with no need for operations or GCC support.

FIG. 6 shows a more detailed block diagram of the system 100 of FIG. 1according to one embodiment. As was described above, the marketparticipants, e.g. traders 104 and market makers 106, interact with theExchange 108 to match 110, clear, 112 and settle 114, transactions. Riskmanagement functionality 116 is provided which monitors and managesmargin requirements, etc., as was described above, to manage andmitigate the risk undertaken by the Exchange 108 and the marketparticipants 104/106 ensuring a stable market. The Exchange 108 furtherincludes one or more account databases 120 which store recordsreflecting, tracking and/or recording the transactions undertaken by themarket participants 104/106 and/or the results thereof. For example, asa market participant 104/106 places orders, completes transactions orotherwise creates positions 620, 622, i.e. matches, settles and clearstrades, the account database(s) are updated to reflect thosetransactions and/or positions 620, 622, thereby allowing the associatedmarket participant 104/106, as well as the Exchange, to audit, accountfor, and manage trading activity.

In one embodiment, a futures account database 602 is provided whichmaintains account records 606 for market participants 104/106 related totheir trading activity of futures instruments. Further, a separate FXaccount database 604 is provided which maintains account records 608 formarket participants 104/106 related to their trading activity of FXinstruments. It will be appreciated, that while the databases 602, 604may be logically distinct, they may be implemented in a single storagemedium and/or data structure and that such arrangements areimplementation dependent and may be further subject to regulatorycontrol.

As discussed above, by acting as an intermediary between marketparticipants 104/106 for the transaction of FX instruments, the Exchange108 obviates many of the requirements of a bilateral system of trading.In particular, the Exchange novates itself into the transactions betweenthe market participants, i.e. splits a given transaction between theparties into two separate transactions where the Exchange substitutesitself as the counterparty to each of the parties for that part of thetransaction, sometimes referred to as a novation. In this way, theExchange acts as a guarantor and central counterparty and there is noneed for the market participants 104/106 to disclose their identities orsubject themselves to credit or other investigations by a potentialcounterparty. For example, the Exchange insulates one market participantfrom the default by another market participant. Market participants104/106 need only meet the requirements of the Exchange 108. Anonymityamong the market participants 104/106 encourages a more liquid marketenvironment as there are lower barriers to participation.

In addition, by acting as an intermediary, the Exchange 108 is able toprovide additional functionality that may not be available in bilateralcontracting situations. In one embodiment, the Exchange 108 provides anetting processor 610 coupled with the FX account database 604 whichanalyzes and/or correlates the various positions 620 within a givenaccount 608 to automatically recognize and/or net positions 620 togetherwhere applicable. For example, when a particular market participant104/106 holds positions 620 which are offsetting with respect to oneanother, those positions 620 may be netted together. Such netting mayreduce and/or eliminate a particular obligation associated with aposition 620, thereby reducing the number of settlement transactionsthat the market participant 104/106 must engage in at the time ofsettlement. In a bilateral trading environment, offsetting positions 620may not be netted together as they may be held with respect to differentcounterparties, possibly under different contractual conditions.Accordingly, the market participant 104/106, in a bilateral tradingenvironment, must settle each position 620 individually. Effectively,the Exchange's role as a central counterparty to transactionsconsolidates the transacting parties to just the Exchange and thetransacting market participant thereby allowing any correlation andsubsequent netting of positions to be performed independent of themarket participant engaging in the counter-transaction or holding thecounter position. With respect to the transactions themselves, the netresult between the bilateral environment and the central counterpartyenvironment of the disclosed embodiments may be the same once allpositions have been settled or otherwise reconciled. However, there areassociated costs with each settlement transaction. Accordingly, byreducing the number of settlement transactions, the transaction costs inthe central counterparty system of the disclosed embodiments are reducedas compared with the costs incurred in the bilateral environment.

In yet another embodiment, the Exchange 108 provides a Collateralprocessor 616 which is operative to determine a collateral value 614 ofa given FX account 608 of a market participant 104/106 and provide thiscollateral value 614 to the risk management functionality 116, such as arisk processor, of the Exchange 108 to be used in offsetting the marginrequirement 618 of that market participant's 104/106 Futures account606. This is referred to as collateralization. In particular, a given FXaccount 608 will have both a monetized risk value 612 and a collateralvalue 614 associated with it. The monetized risk value 612 is themonetary value of risk associated with all of the positions 620 in theaccount. The monetized risk value 612 may be computed similarly to themargin requirement of a future account as has been described. Assumingthere has been no collateralization yet of the particular account 608,the collateral value 614 represents the amount of the monetized riskvalue 612 that the Exchange 108 is willing to allow the marketparticipant 104/106 to pledge against the margin requirement of theirFutures account 606. Initially, the collateral value 614 may equal themonetized risk value 612 or may be slightly less, accounting for a“haircut” reduction to prevent the market participant from pledging theentire value of the account 608. On a periodic basis, as was discussedabove, the Exchange's 108 risk management functionality 116 calculatesthe margin requirement 618 of the market participant's futures account606 based on the positions 622 held within the account 606. Once themargin requirement 618 has been computed, the market participant 104/106may then be permitted to pledge the some or all of the availablecollateral value 614 of their FX account 608 to reduce the marginrequirement. Where the collateral value 614 exceeds the marginrequirement 618, the margin requirement 618 may thereby be satisfied andthe collateral value 614 is reduced by the amount pledged. Thisremaining collateral value may be available to be used against futurerequirements. However, where the collateral value 614 does not satisfythe margin requirement 618, the margin requirement 618 and collateralvalue 614 is reduced accordingly and a reduced margin requirement 618 ispresented, e.g. a margin call, to the market participant for appropriatesatisfaction. As the positions 620 of the account 608 may fluctuate withthe activity of the market, the monetized risk 612 and collateral 614values may similarly fluctuate. This fluctuation will further bereflected in the computation of the margin requirement 618. Overall,collateralization reduces the burden on the market participant 104, 106to meet the margin requirement 618 of his Futures account 606 byallowing them to leverage value that is already being held by theExchange 108.

It will be appreciated that the netting processor 610, collateralprocessor 616, as well as the other functionality of the Exchange 108,including the matching 110, clearing 112, settlement 114 and riskmanagement 116 functionality, may be implemented in hardware, softwareor a combination thereof. In particular, the exchange 108 may provide amatching processor 110, clearing processor 112, settlement processor 114and risk processor 116 to implement the disclosed functionality.Further, this functionality may be implemented in logic or computerprogram code stored in a memory and executable by one or more processorswhich may be directly or indirectly connected, such as via a network.

FIG. 7 depicts flow charts showing the operations of the system of FIGS.1 and 6 according to one embodiment. In particular, in one embodiment, amethod of trading financial instruments among a plurality of entities,i.e. market participants 104, 106, participating in a market isprovided, where the financial instruments include foreign exchangeinstruments. The method utilizes an intermediary, i.e. a centralcounterparty, which, in one embodiment, is an Exchange 108 such as theCME. The method includes recording, in a first account 608 associatedwith a first entity 104, 106 of the plurality of entities 104, 106, afirst plurality of positions 620 resulting from transactions related toone or more of the foreign exchange instruments (block 702). The methodfurther includes maintaining the first account by the intermediary 108(block 704) and receiving from the first entity 104, 106, by theintermediary 108, a request to transact in a particular foreign exchangeinstrument (block 706). In response thereto, the method further includesmatching the request to transact with a counter request received from asecond entity 104, 106 of the plurality of entities and facilitating anexchange of the particular foreign exchange instrument withoutidentifying the first and second entities to each other (block 708) andguaranteeing, by the intermediary, that neither the first nor secondentity will default on their request (block 710).

In an alternate embodiment, wherein the financial instruments furtherinclude futures instruments, the first account 606 may be characterized,based on the first plurality of positions 620, by a monetized risk value612 and a collateral value 614, the collateral value 614 representativeof the monetized risk value 612 less any value pledged as collateral. Inthis embodiment, the method may further include recording, in a secondaccount 606 associated with the first entity 104, 106, a secondplurality of positions 622 resulting from transactions related to one ormore of the futures instruments, the second account 606 beingcharacterized by a net position representative of the offset of one ormore of the second plurality of positions 622 against another one ormore of the second plurality of positions 622 (block 712). The methodmay further include computing a margin requirement 618 for the secondaccount 606 based on the net position (block 714) and receiving a pledgeof a portion of the collateral value of first account to cover themargin requirement of the second account (block 716). In addition,wherein the margin requirement is not satisfied by the pledged portionof the collateral value, the method may further include issuing a margincall to the first entity to fulfill the remaining margin requirement(block 718).

In yet another alternative embodiment, netting may be provided whereineach of the first plurality of positions is associated with anobligation subject to subsequent settlement. In particular, in thisembodiment, the method may further include recognizing a first one ormore obligations/positions which correlate with a second obligation(block 720) and combing those obligation to create a netobligation/position, whereby the second obligation/position may bereduced (block 722) and eliminating the second obligation where it isnullified (block 724), whereby fewer obligations/positions may remainfor subsequent settlement.

The disclosed embodiments also feature Directed RFQ functionality. Inparticular, this functionality permits anonymous and private requestsfor quote, i.e. the request-recipient is unaware of the identity of therequestor but responses are still routed back solely to the requestor.In prior OTC FX markets, transactions were bilateral and therefore thetransacting parties were known to each other, thereby stifling somepotential transactions. Parties needed to know each other so as toevaluate credit risk, etc. In the presently disclosed embodiments, thecentralized clearing mechanism eliminates the credit risk to theparties, as was described above, and permits transacting parties toremain anonymous, with the clearing mechanism acting as the intermediaryand risk buffer. Further, in prior RFQ systems, requests might bedirected to particular market makers but the responses thereto, i.e.actionable quotes, were broadcast back the market generally, increasingthe risk/exposure of the responder. In the disclosed Directed RFQsystem, requests are anonymized and then routed to all of the marketmakers, or alternatively only to an appropriate subset of market makersbased on the parameters of the request (discussed in more detail below).Responses/actionable quotes are then routed back only to the requestorrather than the entire market, thereby limiting the exposure of theactionable quotes and reducing the exposure of the responder(s).

In one embodiment, the Directed RFQ functionality operates as follows:

-   1. A requestor wants to trade a specific amount of a particular    instrument through a Directed RFQ. In one embodiment, the Directed    RFQ communication includes size, price, side (optional), notional    amount, product (currency pair), delivery date and Time to Live    (“TTL”):    -   a. The specific size is can be down to the whole unit ($1) is        not constrained by the “contract size”;    -   b. Directed RFQ has a minimum and maximum quantity range,        defined by currency pair and product type. The minimum can be        lower than the contract size (1 million);    -   c. The front-end should be able to display the quantity        requested in terms of notional amount;    -   d. The trade is all-or-nothing between two        counter-parties—partial fills or not possible (but may be        possible in alternative embodiments);    -   e. In one embodiment, any market participant can submit a        Directed RFQ;    -   f. In one embodiment, the requestor may specify sell-side or        buy-side with the system hiding this information from the market        makers;-   2. A publicly distributed Directed RFQ is broadcast to all, or    alternatively, subset of, market participants;    -   a. This initial Directed RFQ has auto-cancel functionality known        as the Time-To-Live (TTL), which is entered by the requestor;    -   b. The TTL is part of the public Directed RFQ and is sent out        over market data;    -   c. After the TTL expires, the initial Directed RFQ is cancelled;        -   i. In one embodiment, all Directed RFQ Responses which have            not been accepted are canceled;        -   ii. In one embodiment, no more Directed RFQ Reponses are            accepted;-   3. The trading community responds to the public RFQ with a Directed    RFQ Response (new message type);    -   a. Any market participant may respond to the Directed RFQ;    -   b. Each quote may have auto-cancel functionality known as the        Time-To-Live (“TTL”);    -   c. The TTL is entered by the responder, as part of the Directed        RFQ Response;    -   d. Expired responses receive cancel messages;    -   e. Responders can also cancel their quotes at any time;-   4. A Directed RFQ system manages all Directed RFQ Responses it    receives;    -   a. These responses are not put into the public order book, but        are sent to the original requester only;    -   b. Only the Directed RFQ originator can observe Directed RFQ        Responses, along with the TTL associated with each response;    -   c. Each quote is anonymous—containing only the price and TTL. In        one embodiment, whether the request is a buy-side or sell-side        request may be omitted;-   5. The Directed RFQ originator can select from any of the live    quotes in this private order book;    -   a. Once a quote is accepted, the Directed RFQ system then        automatically sends in a Privately Negotiated Trade        (“PNT”)/Block order for the exact notional amount, on behalf of        the two parties;    -   b. All other quotes are immediately cancelled. Cancel messages        to all other responders;    -   c. The Directed RFQ itself is “cancelled” and no more Directed        RFQ Responses will be accepted for it;-   6. Both parties receive normal iLink & Clearing trade reports,    subject to the Consolidate Fill requirements below;    -   a. The system will optionally update the market volume and other        market data statistics based on appropriate configuration        settings.

The Time to Live (“TTL”) parameter may be specified as an absolute timeof expiration, such as a set time, or a relative time, e.g. a durationmeasured from some common reference or origin. In one embodiment,transmission delays in the DRFQ, or in the responses thereto, areaccounted for in computing the TTL window and determining when responsesare properly received therein. In one embodiment, Global PositioningSystem (“GPS”) receivers or some other form of universal time reference,such as a network time reference, e.g. network time protocol (“NTP”), ateach point of transmission may be used to provide accurate timesynchronization and transmission delay detection. Alternatively, thesystem may ignore transmission delays, relying on a central time keepingmechanism as the ultimate arbiter.

In embodiments where Directed RFQ's are routed to only a select subsetof market makers, the selection may be based on trader and/or marketmaker profile information known to the system. Selective routing therebyminimizes quote traffic. In both a broadcast and selective routingenvironment, incentives may be put in place to encourage recipientmarket makers to respond to the Directed RFQ. Incentives may includetrading fee discounts or other incentives. Alternatively, penalties maybe implemented to penalize recipient market makers who fail to respond.Penalties may include fines, increased trading fees, tradingrestrictions or other penalties.

The Directed RFQ mechanism manages all Directed RFQ traffic through thesystem. In one embodiment, in-bound requests are received and a uniqueidentification number is generated and associated with the request, suchas in a log. For example, the request messages/packets, having aparticular data structure, may be received into a buffer storage whichholds the request for subsequent processing. A computer or other numbergenerator then generates a unique value which is concatenated orotherwise associated with the request, such as by being inserted intothe data structure. The Directed RFQ is then pushed out to the market,i.e. broadcast to the market makers, all or a subset thereof, utilizingthe identification number in place of the originator/requestor'sidentification information to identify the Directed RFQ. For example,the various data from the request data structure may be copied into anew message having a similar data structure including the uniqueidentification number but omitting the originator/requestor'sidentification information. The central system maintains a crossreference database/log of the Directed RFQ identification numbers andthe associated requestor identity so as to associate and route responsesappropriately, e.g. at the same time that the anonymous request messageis generated, the data is stored in the cross-reference database. Thisdatabase may be maintained in a memory or other storage device.

In one embodiment, individual Directed RFQ Responses may have TTL whichextends beyond the expiration of the original Directed RFQ Request. Thisis acceptable, and Directed RFQ Responses which have not yet expired arefully executable against by the Directed RFQ originator.

In one embodiment, the Directed RFQ system is managed via a centralserver process. In the event of an “in flight” situation (such as aDirected RFQ Response being cancelled or otherwise expiring while theRFQ originator's acceptance is “on the wire”), whichever request isprocessed by the Directed RFQ central server first, wins. Othertransaction coherency protection mechanisms may also be provided.

Mechanisms may also be provided to allow requestors to manage pendingDirected RFQ requests and responders to manage pending responses. Thiswould allow a requestor, for example, to track which Directed RFQ's areactive, how long they have to live, the present response status, etc.For responders, the mechanisms permit them to know what actionablequotes are still live and how long they have to live. This would allow,for example, a responder to manage responses to multiple Directed RFQ'sto the same product so as not to over expose themselves. For example, anapplication program interface (“API”) may be provided which allowsrequestors and/or responders to access and/or modify the internaldatabase/tables maintained by the DRFQ system to manage requests andresponses and their associated TTL's as will be described. The API maybe a simple command and control interface which receives command/controlmessages, executes the command contained herein and send back a responsemessage to the sender based thereon. Alternatively, the API maybe a webbased interface providing a secure media-rich interactive clientapplication permitting the described management tasks.

FIG. 4 shows an exemplary business message flow for the Directed RFQfunctionality of the disclosed embodiments. It will be appreciated thatother messaging protocols may also be used to achieve the disclosedfunctionality. Further, it will be appreciated that the media over whichthe Directed RFQ messaging traffic flows is implementation dependent andmay include wireless and wired networks, private and publicly accessiblenetworks, or combinations thereof.

In response to a Directed RFQ, there may be multiple responses fromvarious interested parties. These responses may be generatedsubstantially simultaneously or over a window of time as the variousparties receive and react to the Directed RFQ. Further, the transmissionof the Directed RFQ as well as the responses thereto, may be subject tovarious network latencies between and among the disclosed system and thetransacting parties. Further, each response may include differentparameters, including a different TTL. In one embodiment, the DirectedRFQ is matched to the first response which meets the requestedparameters, i.e. the business requirements specified by the requestoriginator, and all other responses are rejected. This matching may beautomatically performed by the system or, alternatively, responses maybe routed back to the originator who then selects the response they wishto trade with based on criteria of their choosing. In one embodiment,the originator may select a desired response based on at least the pricewherein the system then automatically selects among the availableresponses at that price via the mechanisms described below. It will beappreciated that many different matching/selection mechanisms may beutilized ranging from fully automated systems to fully manual systems,and all such systems are contemplated herein.

In an alternate embodiment, the Directed RFQ central server may maintaina private order book on behalf of the originator which maintained, forexample, until the TTL of the Directed RFQ expires. Mechanisms may beprovided which balance the parameters of each response against theparameters/requirements of the Directed RFQ so as to match the mostoptimal response(s) with the request. For example, a “window ofopportunity” may be defined in which responses are allowed to accumulatebefore evaluating those responses and matching to the most optimal. Suchfactors considered in matching requests with responses may include theprice, quantity, TTL (of the request and/or the response), orcombinations thereof. Once the “window of opportunity” closes, allsubsequently received responses are rejected even if they may be moreoptimal than an accepted response. In one embodiment, the “window ofopportunity” may be dynamic and may be based on the latest expiringresponse which meets one or more of the request parameters.Alternatively, the “window of opportunity” may be statically defined ormay be defined by a parameter of the Directed RFQ itself on atransaction by transaction basis, such as by the TTL of the DirectedRFQ. Typically, the requestor will desire a long TTL on the responses toallow for the best selection of quotes while the responder will want ashort TTL on the response to minimize exposure/risk. Once the windowcloses, the central server evaluates the received responses and takesthe best price which matches the originator's requirements (as stated inthe Directed RFQ). The system may then execute a block trade on behalfof both parties to complete the transaction. In one embodiment, multipleresponses which tie for the best price or otherwise meet therequirements may be subject to selection by First in First Out, or otherarbitration mechanism such as round-robin. Once the transaction iscomplete, fill notifications are sent back to both parties, etc.

Given the transmission latencies noted above, a given response mayarrive at the system later than a later-generated response or miss theTTL of a given Directed RFQ, and may therefore miss a matchingopportunity, depending on the transmission latencies in the system. Inone embodiment, logic is included to evaluate responses based on thetime they are generated and the time they are actually received tomitigate “in-flight” discrepancies and otherwise maintain coherencybetween Directed RFQ's and the responses thereto, ensuring equalopportunity to the market participants and minimizing re-transmission ofrequests and responses.

In one embodiment, Directed RFQ transactions occur outside of the normalcentral order book. In an alternative embodiment, a particular DirectedRFQ may be allowed to match against the central order book where asuitable order is present.

In one embodiment, conditional responses to a Directed RFQ may besupported allowing a responder to attach conditions to theirresponse/actionable quote. Matching of the response to the requestfactors in whether the specified conditions are met, in addition toother factors.

In an alternative embodiment, indicative quoting is also supportedallowing market makers to publish indicative quotes to the market placeand invite Directed RFQ's from interested parties prior to issuingactionable quotes.

More information regarding Directed Requests For Quotes may be found inU.S. patent application Ser. No. 11/452,653, entitled “SYSTEM AND METHODFOR DIRECTED REQUEST FOR QUOTE”, filed Jun. 14, 2006, and published asU.S. Patent Application Publication No. 2007/0118455 A1, the disclosureof which is herein incorporated by reference.

In one embodiment, Mass Quoting and associated market maker protectionsare supported for Directed RFQ trade flow. Where market makerprotections are triggered, by either a Directed RFQ or CLOB-basedmechanism, both the MassQuotes in the existing CLOB markets would becanceled and, additionally, any active Directed RFQ responses would alsobe immediately cancelled by the system.

In one embodiment, the market maker protections include those providedby the CME Falcon trading engine and include protections specified inTable 2 below.

Table 2

-   10. Falcon provides Enhanced Market Maker Protection-   10.1 Falcon restricts the number of fills, the number of matched    trades, or the number of contracts occurring within a CME defined    time interval.-   10.1.1 The restriction time is defined at the Group Level.-   10.1.2 Market Maker protection applies to MASS QUOTER's only.-   10.1.3 Market Maker Protection (MM Protection) applies to incoming    Mass Quotes and resting Mass Quotes only.-   10.1.4 Market Maker Protection applies to each side of a Quote    separately.    -   Note: Market Maker Protection does not apply to Orders submitted        by a Market Maker.-   10.1.5 The CME defined time interval (variable N) is input via FAS    and is applied at the Group level.-   10.1.5.1 The variable N is only applied to Products eligible for    Mass Quotes.-   10.1.5.2 The variable N is based on a Trading Engine established    heartbeat.-   10.1.5.3 The heartbeat will commence randomly at start-up.-   10.1.5.3.1 The heartbeat will commence at the same time for each    Group.-   10.1.5.4 The variable N may be changed on a real-time basis.-   10.1.5.4.1 A variable N change takes place at the end of the current    N period.-   10.1.5.5 The variable N is maintained for MASS QUOTERs at the Group    Level.-   10.1.5.6 N resets at the end of N time period, whether market action    occurs (execution/quote entry/etc.) or not.-   10.1.5.7 Mass Quoters setting/resetting MM Protection to Y enter the    N time period in progress. Note: no unique N time clock for MQ.-   10.1.5.8 N variable is maintained at Millisecond level-ssSSSS.-   10.2 Falcon realizes three protection mechanisms applied at the    group level for MASS QUOTERs: New Fill Protection (X), Execution    Protection (Y), Quantity Protection (Z)-   10.2.1 New Fill Protection (X)-Falcon tracks the total new quote    executions per new quote side for all instruments within a Group for    a MASS QUOTER.-   10.2.1.1 A count starts at 1 for a Group when an execution occurs    for a new quote side.-   10.2.1.1.1 The size of the executions and number of executions do    not affect the count for the specific instrument's quote side.-   10.2.1.1.2 Executed Cancel/Replace and New Mass Quotes occurring    within the N time period for an instrument's quote side within a    group increment the count by 1.-   10.2.1.2 The count increments by 1 for a Group for every execution    occurring against a new quote on a quote side for an instrument    group within the N time interval.

Note: New quote is defined a modification of an existing quote or aquote entered after a total fill for an instrument.

-   10.2.1.3 New Fill Protection (X) is determined by the MASS QUOTER    and is modifiable at the FAS.-   10.2.1.3.1 Setting the New Fill Protection to 0 turns off the    protection.-   10.2.1.4 The count X is reset every time a new N time interval    starts.-   10.2.1.5 Mass Quote Cancels do not impact the value of X.-   10.2.1.6 MM protection is triggered when X is greater than or equal    to the MASS QUOTER defined X value.-   10.2.2. Execution Protection (Y)-Falcon tracks the total number of    executions per quote side for all instruments within a Group for a    MASS QUOTER.-   10.2.2.1 A count starts at 1 for a Group when an execution occurs    for a quote side.-   10.2.2.2 The count increments by 1 for a Group for every execution    occurring against a quote on a quote side for an instrument (in the    Group) within the N time interval.-   10.2.2.3 Execution Protection (Y) is determined by the MASS QUOTER    and is modifiable at the FAS.    -   10.2.2.3.1 Setting the Execution Protection (Y) to 0 turns off        the protection.-   10.2.2.4 The count Y is reset every time a new N time interval    starts.-   10.2.2.5 Mass Quote Cancels have no impact on the value of Y-   10.2.2.6 MM protection is triggered when Y is greater than or equal    to the MASS QUOTER defined Y value.-   10.2.3 Quantity Protection (Z)-Falcon sums the total quantity of    executed trades per quote side for all instruments within a Group    for a MASS QUOTER.-   10.2.3.1 Aggregation starts for a Group when an execution occurs for    a quote side.-   10.2.3.2 The sum increases for a Group by the trade quantity amounts    occurring against quotes on a quote side for an instrument (in the    Group) within the N time interval. [Note: quantity in instrument,    not leg totals of instrument]-   10.2.3.3 Quantity Protection (Z) is determined by the MASS QUOTER    and is modifiable at the FAS.    -   10.2.3.3.1 Setting the Quantity Protection (Y) to 0 turns off        the protection.-   10.2.3.4 The sum Z is reset every time a new N time interval starts.-   10.2.3.5 Mass Quote Cancels have no impact on the value of Z    10.2.3.6 MM protection is triggered when Z is greater than or equal    to the MASS QUOTER defined Z quantity value.-   10.3 Market Makers determine the X, Y, and Z values at the Group    Level.-   10.3.1 Falcon engine maintains the MM defined X,Y,Z values at the    Group Level.-   10.3.2 X,Y,Z values are entered and maintained via the FAS at the    Group level.-   10.3.3 X,Y,Z values are modifiable on a real-time basis.-   10.3.3.1 Changes do not take effect until the end of the N time    period.-   10.3.4 X, Y, and Z data type is Long-   10.3.5 X, Y, and Z values can be between 0 and max. value.-   10.3.6 X, Y, and Z cannot be negative.-   10.3.7 If the Fill Protection count is greater than X, or the number    of executions greater than Z, or the quantity of contracts traded is    equal to or greater than Y per Group within the N interval, MM    Protection is triggered.-   10.3.7.1 When MM Protection is activated, Falcon cancels the Quotes    for all instruments within the Group for the MASS QUOTER's    SenderCompID.    -   10.3.7.1.1 Quote Entries within the Mass Quote message which        trigger MM protection are cancelled and added to the Number of        Cancels Accepted field. Cancel/Replace QuoteEntries are only        counted once.    -   10.3.7.1.2 The QuoteEntry which triggers MM Protection generates        an execution.    -   10.3.7.1.3 Any remaining quantity is cancelled and added to the        Number of Cancels

Accepted field.

-   10.3.7.2 Falcon sends a Mass Quote Cancel Confirmation message with    a Quote

Status of F.

-   10.3.7.3 MM Protection is not enforced when the X, Y, Z variables    are met in mid-matching.-   10.3.7.4 MM Protection is triggered after the quote which causes the    X, Y, or Z variable to trigger completes a matching process.-   10.3.7.5 Mass Quote messages which trigger MM Protection are    returned an Ack before cancellation message.-   10.3.8 When MM Protection is triggered, Falcon does not accept any    new Mass Quotes for a MASS QUOTER in the triggered Group.-   10.3.8.1 Falcon rejects Mass Quotes for the MASS QUOTER in the    Group.-   Message Reject Code and Reason Text will denote that MM Protection    has been initiated.-   Message Reject Code=00-   Message Reason Text=“ ”-   10.3.8.1 Falcon accepts Quotes in the triggered Group if the Market    Maker Protection reset flag Tag 9773 has been reset to Y in a Mass    Quote Msg by the MASS QUOTER.    -   10.3.8.1.1 The value received from the MASS QUOTER is echoed        back to the MASS QUOTER.    -   10.3.8.1.2 If the value of the reset flag is N and MM Protection        is in effect, Falcon sends the following reject:    -   Quote status=5    -   Reject code=98    -   Reason Text=“Market Maker Protection”    -   10.3.8.1.3 After the MASS QUOTER submits the Protection Reset        flag set to ‘Y’, they may continue to enter Mass Quotes with the        flag set back to ‘N’.-   10.3.8.2 Falcon accepts Quotes in the triggered Group if the Market    Maker

Protection reset flag Tag 9773 has been reset to Y for the MASS QUOTERby the GCC via FAS.

-   10.3.8.3 The MM Protection is triggered if an inbound Mass Quote    message contains more than 110 invalid quotes.    -   10.3.8.3.1 If more than 110 quotes within a Mass Quote message        are invalid, the Falcon rejects the entire message and cancels        all resting quotes in the Group for the MASS QUOTER.    -   10.3.8.3.1.1 Reject and cancellation occur whether MM Protection        flag is on or off.    -   10.3.8.3.1.2 Mass Quote Cancel Confirmation Message set as        follows: Cancel_Status=“F”, Reject_Code=00, Reason_Text=“ ”    -   10.3.8.3.1.3 Falcon will continue to reject Mass Quotes until        the MASS QUOTER receives a Protection reset flag in a Mass Quote        Message    -   10.3.8.3.1.4 Subsequent Mass Quotes Messages received before        reset will be rejected and sent a Mass Quote Confirmation        message with a Quote Status of 5.    -   Message Reject Code=98    -   Message Reason Text=“Market Maker Protection”-   10.3.8.4 In the event of a Falcon Engine restart, new MassQuote    Messages are accepted regardless of the Protection Reset flag.-   10.3.8.5 Falcon does not reset Market Maker Protection status when    entering the close or pause state.-   10.3.8.6 Falcon does reset Market Maker Protection on the last    scheduled close of a trading week.-   10.3.8.7 MM Protection is on if X, Y, Z has values present.-   10.3.8.8 MM Protection is off if X and Y and Z have 0 values.-   10.3.8.9 MM Protection default value is 0 for X and Y and Z.-   10.4 Over two N time periods, the worst case exposure for a Mass    Quoter is two times the X or Y or Z variable minus 2 of that    variable.-   10.5 Falcon executes ACKs for MQ quotes before Canceling when MM    Protection is triggered.

In the disclosed embodiments, the Market Data functionality ensures thatmarket data is efficiently and accurately communicated to the marketparticipants. All market data for these markets may be in notionalterms, i.e. expressed as the face value of the underlying instruments onwhich derivatives are traded, but other representations may be used.

Market data for the Central Limit Order Book may include:

The market depth of the Top of Book MA message (and Implied Top of BookMY message) at 5.

-   -   Consolidated fills    -   Spreads and legs and/or spread quantities Market data for the        Directed RFQ may include:    -   The request message (and expiration message);    -   The fill and fill price.

In the disclosed systems, quotes and order book updates are anonymousand Traders cannot directly advertise their quotes.

Market statistics may include:

-   -   Update volume, high, low, last from central limit order book;    -   For block trades in this market, the market data statistics,        such as the overall volume, high, low and last, will be updated        based on the existing rules (these rules are defined in the EOS        2.0 RFC/Blocks feature set);    -   For Directed RFQ

In the disclosed embodiments, for Swap trades, market data for Spot andthe Forward outright legs is disseminated. For reciprocal markets, thosewhich use a Spot from another associated market, this market data mustbe rounded in some fashion.

In the disclosed embodiments, the Trade Data functionality ensures thattrade and order data is efficiently and accurately communicated to themarket participants.

Consolidated fill notifications need to be distributed immediately aftera match, independent of the venue the match occurred:

Notification to the front-end;

-   -   Notification to the clearing house;    -   Notification to the trade (account) owner's clearing firm;    -   Notification to a trader's back office system (open question);    -   Notification to market data (conditional on venue);

Consolidated Fill:

-   -   Front-end—sending only a single fill notification per aggressor        order, per price level, regardless of the number of        counterparties;    -   This could be accomplished either via modifying existing iLink        FIX messages (and overall messaging model) or via message        aggregation on the front-end;    -   Back-end—similar to the front-end consolidation, there would        only be a single notification per aggressor order, per price        level, regardless of the number of counterparties and individual        trades involved. It may be critical to this portion of the        Consolidated Fill is that the consolidation rules match the        Front-end rules exactly.

Fill notifications should include

-   -   Forward swaps—the Swap with the differential, the Spot leg with        its associated value date, and the forward leg with its        associated value date.        -   This will require either using the D1 message (as well as            the M1) from the Match Engine to Clearing, or a new            interface/message altogether. D1 and M1 are trade messages            sent by the trading engine to the clearing and reporting            organizations. See the Section below on Clearing/Settlement            for more information;    -   Spot contracts—the generic Spot contract and its associated        value date;    -   Forward out-rights—the generic forward out-right, and it's        associated value date.

In the disclosed embodiments, counterparty information may not beincluded in the fill notification:

-   -   To the front-end;    -   To the clearing firm.

Trade reporting maintains the original trade price & date to match cashmarket convention. Trade reporting is currently done via FIX ML andTREX, while the industry standards in OTC FX such as TOF, TWIST, &SWIFT. In the disclosed embodiments, clearing supports trade messages inthese major OTC FX formats. In one embodiment, DealHub or a similarservice can be used to convert from an originating CME format to one ofthese OTC FX standards.

Trade reporting is done in notional amount, rather than in quantity ofthe contract, using FIX ML as an originating CME formats.

In the disclosed embodiments, the Clearing/Trade Reporting/STPfunctionality essentially performs the trading functions of theExchange. Clearing handles all instrument creation & modification forthe Match Engine. As noted above, the Swap contract symbols do notchange daily. In one embodiment, each day the most economicallyappropriate end-of-day settlement prices for open contracts needs to bedetermined, so as to mark open positions to market. Daily settlementswill result in unrealized gain/loss. Pending deliveries, unrealizedlosses will be collateralized (rather than daily banking of thatmark-to-market amount).

The collateral requirements are based on:

-   -   The exact amount of unrealized gain/loss so far;    -   The maximum reasonably likely loss over the next trading day, as        determined by SPAN according to parameters we set; and    -   CLS requirements for capital against expected settlement        obligations;

Settlement/trade reporting contains information on the spread traded aswell as the outright legs (with the implied linkage between legs &spread present):

-   -   Clearing will optionally compress trades, based on client/CLS        need (note that this is not pre-netting, as that would zero out        a buy & sell whereas compression would not);    -   Clearing will optionally pre-net trades, based on client/CLS        need;    -   This pre-netting or compression can be done on a per currency        level of granularity;    -   All settlements will be made through Continuous Linked        Settlement Bank (CLS);    -   For normal open positions with the two-day value date        convention, we will be sending transactions to CLS between 4 and        5 pm Chicago time—needs to validated against existing OTC        practices;    -   Normal clearing settlement-cycle timelines will not be affected        and will remain 7 pm for completion of all post-trade activity        prior to the second day before the value date; and

Settlement reports are generated for each clearing firm enumerating eachaccount's specific activity.

In an alternative embodiment, support for Bilateral Credit, Give-Up's,Average Pricing (APS) and Single Line Entry of Differential Spreads(SLEDS) is provided.

Post-Trade Account number modifications are not allowed in this market

For Clearing/Trade Reporting, as mentioned above, the disclosedembodiments may use one of several options which are implementationdependent:

1. Pre-net each side by trade; or2. Pre-net each side by trade date.

CME Clearing House can settle directly through CLS for each clearingfirm. If that clearing firm has CLS standing instructions for a givenaccount, CME can clear through CLS to the account level.

In the disclosed embodiments, the Fee functionality permits the Exchangeto charge transaction fees and other wise obtain compensation for use ofthe provided trading mechanisms. The Fee functionality accounts fortrading and other activities and appropriately obtains compensation fromthe transacting parties.

For the purposes of Fees, this will be a new class of marketparticipant.

The system will have the ability to fee by the following:

-   -   Discrete quantity tiers; and/or    -   Aggressor orders.

All quantity is in notional terms.

This market will be a “Payout” versus a “Revenue Share”

The attributes or qualities of a Market Maker, for the purposes of Feesonly, can be defined in the following terms:

-   -   SubscriberAlias—Where the order is coming from (i.e. a desk);    -   TraderID—Who the order is coming from; and    -   Account—For whom is this order.

The buy/sell file from Clearing must include the ‘aggressor order’indicator as well as information about what product this trade was apart of (specifically, in the case of a Swap, the buy/sell filetypically only includes the legs, with no reference to the spread).

There is the potential for a negative fee.

The Fee functionality handles the new transaction type which is theBlock trade resulting from a Directed RFQ which is different from anormal Block or Ex-Pit transaction.

In one embodiment, a variable fee structure may be provided in whichfees vary as a function of the risk of the transaction and/or of thetrading party.

The Front-End/Distribution functionality of the disclosed embodimentsinclude the interfaces, e.g. Application Program Interfaces (“API's”),GUI, etc. which permit the receipt of orders, Directed RFQ's, etc. fromthe market participants and the dissemination of trade and market datato the market participants.

Access and market data for Independent Software Vendor (“ISV”) andProprietary front-ends into the Central Limit Order Book (“CLOB”) andDirected RFQ will be available through API's:

-   -   In one embodiment, CME will distribute this new market via iLink        2.0, CME's market data API, only, with the required API        enhancements to encompass the new order types and this        marketplace; and    -   This market will use the existing market data infrastructure.

API access will be made available to any approved entity as determinedby FX Marketplace:

FX Marketplace must be able to prevent selected front-ends and datacenters from accessing it (for example EBS);

ISVs may also be permitted to create access for authorized users (i.e.OTC market ISVs) via a GCC operated registration process. These marketsare not generally available to all traders on the ISV network;

A front end may take one of three forms:

-   -   Deal with Reuters, using the existing CME interfaces (updated        iLink 2.0 API, Clearing link described above, market data);    -   New product development, either internal or through a joint        venture dependency; or    -   Update and existing CME front end (EOS/GL/CME.com).

In one embodiment, the front-end is browser based, rather than astand-alone application. The front-end must know the real-time, fullproduct definitions, inclusive of value dates for Spot and Swap markets.ISV's may also be permitted to create access for authorized users (i.e.OTC market ISV's). This system is not generally available to all traderson the ISV network.

The Distribution/Front-End system employed here would optionally conformto the Consolidated Fill guidelines mentioned above. In one embodiment,the system has the ability to deliver this information in the requiredindustry formats currently used in the OTC FX space.

In one embodiment, additional trading functionality is provided totransacting parties. For example, in one embodiment, Implied Spreads inCurrencies are provided. This function permits implying/interpolatingprice in one of multiple inter-related markets based on (sufficient)pricing data known in the remaining markets. Exemplary inter-relatedmarkets are: spot rate/swap rate/forward outright; cross currency (A/B,B/C, A/C) (across or within product lines), e.g.dollar/yen-yen/euro-dollar/euro; and between broken dates. In the caseof an incoming order for a swap market in currency A/B, the swap isbroken down into its two forward legs for said currency pair. These legscan be used to imply open interest in reciprocal markets or in thoseforward markets using either specific currency.

In another embodiment, Intra-Firm Match Avoidance protections areprovided to prevent a particular entity from transacting with itself.The system prevents firms or traders from matching with themselves inany of the central limit order book markets. This may be accomplishedusing information on the order at the trader, desk, or firm level ofgranularity. When an aggressor order is matching the resting book andthe opposite order has been deemed to be unmatchable, there are severaloptions: The aggressor order is cancelled before any matching occurs; orThe aggressor order matches normally and any resting order it attemptsto match with, which is deemed unmatchable, is cancelled immediately. Ineither case, appropriate fill and cancellation messages are sent to theparties involved, per normal operations of those actions (order canceland trade).

In another embodiment, Universal Pass Through is provided which allowsparties to swap interest rates among currencies where the clearing housetakes over the credit risk/funds transfer mechanism.

In another embodiment, shown in FIG. 5A, Flexible Hybrid CentralCounter-party Cross-Margining or Cross Collateralization is supported.In particular, one-bucket and two-bucket cross-margining orcollateralization processes are combined into a single streamlinedprocess. Cross-Margining or Cross-Collateralization allows for areduction in margin or collateral amount requirements for trading ineither OTC or exchange traded derivatives markets. This reduction ispossible because assessed risk is reduced when offsetting (risk-offsetor ‘Spreadable”) positions are cleared by the same or affiliated“clearing members” or market participant firms at the cross-marginparticipating central-counterparty clearing organization(s).

In the present embodiment, both one-bucket and two-bucketcross-margining or collateralization processes are combined into a onestreamlined and single process by combining ‘One-pot Approach’ and‘Two-pot Approach’ to support both OTC and exchange traded derivativesclearing transactions. Process 1: 1 Pot Approach is initially achievedwith two or multiple partnering parties. Process 2: 2 Pot Approach isachieved with one or multiple partnering parties dealing withrisk-offset eligible positions after the process 1 is done.

Referring to FIGS. 5B and 5C, the 1 Pot Approach is shown:

Clearing Transactions Scope Participants: clearing members of exchangeor counter-parties in the OTC market

-   -   Multiple contracts or products of all types (both OTC and        exchange traded) at different exchanges or counter-parties        -   All Cross-Margin Activity=Joint Cross-Margin/collateral            Account        -   Identified with a Separated into Cross-Margin Origin        -   It is separate from participant's normal clearing at            respective clearing organizations, entities or            counter-parties.    -   Only ALLOW Cross-Margin/Collateral Eligible Trades to Clear in        the Joint Cross-Margin/Collateral Accounts    -   Trades executed directly into the Cross-Margin Accounts    -   Positions can be transferred between a normal Clearing Account        and Cross-Margin Clearing/Collateral Account.    -   Separate Position Records/Data is submitted for the Cross-Margin        process Origin    -   Banking Settlement or collateralization only Dedicated to the        Joint Cross-Margin Accounts        -   Treated as Separate Origin        -   Separate Bank Accounts, Wires, Transactions, etc.

Referring to FIG. 5D, the 2 Pot Approach is shown:

-   -   Transactions of Participating Clearing Organizations=Occurs at        Each Clearing Org.+Offset Risk=2 Pot    -   No Joint Cross-Margin Accounts    -   No Separation from Clearing Member's Primary Clearing Account at        respective clearing organizations    -   Hold Collateral in the Same Separate Firm Accounts

Each Participating Organization Calculates its PB Requirements, Offsetand Share Offset, Gain & Loss Guarantee Information

-   -   Positions Remain at each participating organization origin    -   No Need for Position Transfer into Cross-Margin Account    -   No Separate Position Change Submission (PCS) report is Needed    -   Transparent Transaction    -   For example,    -   CME offers credit on cross-margin eligible contracts for        offsetting positions at the opposite clearing organizations    -   Opposite Clearing Org. will offer credits on their positions.    -   No Dedicated Banking Settlement for Cross-Margin Purposes    -   No Separate Bank Accounts, Wires, Transactions, etc.    -   Transactions become part of current banking transactions.

In the 2 Pot approach, Cross-Margin Offsets are Calculated as follows:Internal Process for Cross-Margin Eligible Product:

-   -   1. Do all Internal Intra-Commodity Spreading.    -   2. Do all Internal Inter-Commodity Spreading.    -   3. Look at the available cross-margin delta positions at other        clearing organizations to see if additional spreads could be        formed from CME's remaining delta positions.    -   4. Allocate Prioritized Spread Credit to each Clearing        Organization        -   i.e. Multiple organization cross-margin program.        -   Assign Priority from Highest to Lowest spread credit amounts            based on the information from other participating clearing            organizations.        -   Calculate the Spread Allocation based on the priority.

FIG. 5E shows the process for dealing with positions that were notoriginally offset. FIG. 5F shows how cross-margining utilizes X-marginmargin that was not offset. FIG. 5G demonstrates how cross-marginingmatches positions of similar absolute risk at two or more clearingorganizations.

Allocation of Savings on Proportional Basis:

-   -   Cross-Margining with Multiple Organizations,    -   Allocation of its Positions and Margin necessary    -   Allocations Will Optimize Members' Margin Reductions        -   Amounts are First Allocated to Products With Best            Correlations        -   If Equally Correlated, Allocations Are Pro-Rata Based on            Margin Amounts Submitted by Each Clearing Organization

Exchange CME LCH GSCC Eligible Contract Eurodollar Euribor Treasury Eq.Eligible Delta 1000 −700 −500 Spread Credit % 80% 35% Spreads Formed1000 −700 −300 Remaining Delta 0   0 −200

The 2 pot approach offers the advantages of: flexibility in managingcollateral is unaffected using “Two Pot” Approach; avoids legal andoperational complexities of establishing and maintaining joint marginAccounts in a multiple-clearing organization cross marginingenvironment; the ability to pledge margin collateral for liquiditypurposes is unaffected; and there is no operational impact except inperforming an audit trail.

In another embodiment, pricing of the swap legs, using the mid-point inthe spot market is provided, with error handling where the spot marketis illiquid. In particular, as used herein, “Spot” refers to the day onwhich deals agreed today are actually carried out. In the foreignexchange markets, spot is usually two working days ahead; so for dealsconcluded on Tuesday, spot is Thursday; for deals concluded on Friday,spot is Tuesday (unless bank holidays intervene). A spot deal is asimple exchange of two volumes of currency to take place two workingdays ahead—in other words, with a value date of spot. The foreignexchange rates commonly quoted in the media are spot rates—the ratesagreed in today's spot deals. The term “Outright/Forward” refers to asimple Forward exchange of two volumes of currency where the value dateis any date other than spot. The rate for the deal is normally quoted asa premium or a discount (‘negative premium’) on top of the current spotrate. So the formula for the dealt rate (the rate specifying therelationship between the two volumes) is:

Dealt Rate=Spot Rate+Premium, or

Dealt Rate=Spot Rate—Discount

In a swap deal, a volume of one currency is exchanged for a volume of asecond currency. After an agreed period, the transaction is reversed. Itis possible for the volumes in the second ‘leg’ of the transaction todiffer from the first. For example, a deal might specify that at spot:

Bank A pays 5,000,000 US Dollars to Bank B

Bank B pays 7,565,000 Swiss Francs to Bank

A (Rate 1.5130)

. . . and that three months later:

Bank B pays 5,000,000 US Dollars to Bank A

Bank A pays 7,530,000 Swiss Francs to Bank

B (Rate 1.5060)

The difference in the rates of the second currency for the two legs ofthe swap deal arises from differences in the deposit rates for the twocurrencies, and expectations about variations in the spot rates.

In one embodiment, the disclosed system will:

-   -   Price a Spot and Forwards in absolute terms (i.e. the rate); and    -   Price Swap in differential terms.        When a trade on a Swap occurs, the system has the agreed upon        differential between the Spot and the Forward leg. At this        point, the system anchors the Spot for the transaction as the        mid-point between the bid/ask in the current Spot market.

Additionally, four alternative mechanisms for how to assign the legprices to the CME FX Swaps are provided if there are no bid and askprices for a given currency in CME FX Spot:

1. Use Reuters contributor spot FX pages (such as EUR=, JPY=, CAD=,GBP=, CHF=, AUD=) and take the average of the spot bid and askquotations at the time of the trade;

2. Use Reuters Dealing Terminal Quotations (perhaps utilizinginformation from CME GFX) for the target currencies and calculate theaverage of the spot bid and offer to use in assigning SWAP leg prices;

3. Use a combination of Reuters Dealing Terminal Quotations for itsstrong currencies and CME GFX spot resources for the EBS strongcurrencies;

4. Use CME currency futures prices (bid and ask on CME Globex) for thenearby (most active) contract month and use Reuters forward points (or acombination of Reuters and Bloomberg forward points) to the IMM dates tostrip out the synthetic spot bid and ask for pricing the CME SWAP legprices. Simply average the bid and ask of these synthetic spot prices toassign the CME SWAP leg prices. This may be similar to CME trading flooroperations' plans to use an analogous version of this technique to setCME FX futures settlement prices for the expiring months during theone-week rollover period by using the next deferred, moreactively-traded CME FX futures contract prices and forward points toback out the expiring CME FX futures settlement price.) CME tradingfloor operations has a program that could possibly be modified to backout spot bid and asks from CME FX futures prices; or

5. Use the last price in the Spot market, through a certain age. If thelast spot price was too old, this spot price would backstopped by the“daily settlement price” used to determine unrealized gains and losses(thus, never more than 24 hours old). However, number 4 above could workas an alternative for any time there is no spot, and if there are nofutures bids and offers on CME Globex, then it could be backstopped bythe last spot, and if no last spot price that day, could further bebackstopped by the last daily settlement price.

It is therefore intended that the foregoing detailed description beregarded as illustrative rather than limiting, and that it be understoodthat it is the following claims, including all equivalents, that areintended to define the spirit and scope of this invention.

We claim:
 1. A computer implemented method comprising: receiving via anelectronic communications network by a processor of an intermediaryelectronic trading system from a first entity of a plurality of entitiesa first request for a first transaction in a particular financialinstrument, wherein the first request comprises data indicative of atime of transmission by the first entity; identifying, by the processor,a second request previously received via the electronic communicationsnetwork by the intermediary electronic trading system from a secondentity of the plurality of entities for a second transaction in theparticular financial instrument where the second transaction is at leastpartially counter to the first transaction, wherein the second requestis characterized by a time period within which a suitable countertransaction will be accepted; evaluating, by evaluation logic of theprocessor, the time of transmission of the first request so as tocompensate for any network transmission latency of the electroniccommunications network and comparing the time of transmission with thetime period of the second request and further determining that the firstrequest was at least transmitted to the match processor prior toexpiration of the time period regardless of whether the first requestwas received thereafter; and matching, by the processor, the firstrequest with the second request based on the determination that thefirst request was transmitted prior to the expiration of the time periodand subsequently facilitating the first and second transactions withoutthe intermediary electronic trading system communicating dataidentifying the first and second entities to each other.
 2. The computerimplemented method of claim 1, wherein the facilitating furthercomprises: initiating performance of the first transaction between thefirst entity and the intermediary electronic trading system andinitiating performance of the second transaction between the secondentity and the intermediary electronic trading system wherein if it isdetermined that one of the first and second transactions matched by thematch processor is incapable of being completed, performance of theother of the first and second transactions proceeds unaffected; andrecording, in a first account stored in a database coupled with theintermediary electronic trading system and associated with the firstentity, data indicative of a first position resulting from at least theinitiation of the first transaction and indicating that the firsttransaction is yet to be completed, the first position being one of aplurality of positions for which data indicative thereof is recorded inthe first account as a result of at least initiation of performance of aplurality of other transactions received from the first entity each ofwhich is yet to be completed, wherein each of the plurality of othertransactions is subject to subsequent completion between theintermediary electronic trading system and the first entity, each of theplurality of other transactions being associated with acounter-transaction matched with the other transaction by theintermediary electronic trading system.
 3. The computer implementedmethod of claim 2, further comprising: recognizing, by a nettingprocessor, the first position of the plurality of positions in the firstaccount at least partially correlates with a second position of theplurality of positions in the first account, the correlation beingindependent of them being recorded in the same account and independentof the counter-transaction associated with the at least one transactionfrom which the first and second positions resulted; combining, bynetting processor, the recognized first position with the secondposition to create a net position and recording the net position in thefirst account, wherein at least one of the recognized first position,the second position or combinations thereof are nullified by thecombining; and eliminating, by the netting processor, the recognizedfirst position, the second position or combinations thereof, along withthe associated transactions and data indicative thereof stored in thedatabase, that are nullified by the combining; whereby fewer positions,as well as the data indicative thereof, remain in the first account anddatabase for subsequent completion of the associated transactions. 4.The computer implemented method of claim 2 wherein the initiating andrecording are performed by a system different from the intermediaryelectronic trading system.
 5. The computer implemented method of claim1, wherein the matching further comprises substituting the intermediaryfor the second entity in the first transaction and substituting theintermediary for the first entity in the second transaction.
 6. Thecomputer implemented method of claim 1, wherein the first account ischaracterized by a monetized risk value representative of the at leastone position and a collateral value representative of the monetized riskvalue less any collateral value pledged as collateral, the methodfurther comprising: recording, in a second account associated with thefirst entity, at least one position resulting from at least onetransaction related to one or more futures instruments; computing amargin requirement for the second account based on the at least oneposition of the second account; receiving a pledge of a portion of thecollateral value of the first account to cover the margin requirement ofthe second account; and reducing the collateral value of the firstaccount and the margin requirement of the second account based on thepledge.
 7. The computer implemented method of claim 1, wherein theparticular financial instrument comprises one of a forward, spot or swapinstrument.
 8. The computer implemented method of claim 1, wherein thesecond request was anonymized and routed, upon receipt, to all of theplurality of entities, the matching further comprising anonymizing androuting the first request back only to the second entity.
 9. Thecomputer implemented method of claim 1, wherein the second request wasanonymized and routed, upon receipt, to only a subset of the pluralityof entities, the matching further comprising anonymizing and routing thefirst request back only to the second entity.
 10. The computerimplemented method of claim 1, wherein the time period of the secondrequest within which a suitable counter transaction will be accepted isdefined relative to a common reference.
 11. The computer implementedmethod of claim 1, wherein the first request is one of a plurality ofreceived requests received by the processor which are determined to haveat least been transmitted prior to the expiration of the time period,the matching further comprising selecting the first request from amongthe plurality of received requests based on criteria specified by thesecond request.
 12. A system comprising: computer executable programcode stored in the memory and executable by a processor to implement: arequest receiver operative to receive, via a communications networkcoupled with the processor, a first request from a first entity of aplurality of entities for a first transaction in a particular financialinstrument; a match identifier coupled with the request receiver andoperative to identify a second request previously received via thecommunications network from a second entity of the plurality of entitiesfor a second transaction in the particular financial instrument wherethe second transaction is at least partially counter to the firsttransaction, wherein the second request is characterized by a timeperiod within which a suitable counter transaction will be accepted;evaluation logic operative to evaluate the first request to determinethe time of transmission of the first request so as to compensate forany network transmission latency of the electronic communicationsnetwork and compare the determined time of transmission with the timeperiod of the second request and further determine that the firstrequest was transmitted to the match processor prior to expiration ofthe time period regardless of whether the first request was receivedthereafter; and a match processor coupled with the match identifier andoperative to match the first request with the second request based onthe determination that the first request was transmitted prior to theexpiration of the time period and subsequently facilitate the first andsecond transactions without an intermediary electronic trading systemcommunicating data identifying the first and second entities to eachother.
 13. The system of claim 12, further comprising: a settlementprocessor coupled with the match processor and operative to initiateperformance of the first transaction between the first entity and theintermediary electronic trading system and initiate performance of thesecond transaction between the second entity and the intermediaryelectronic trading system, wherein the settlement processor is operativeto determine when one of the first and second transactions matched bythe match processor is incapable of being completed, and, upon thatoccurrence, operative to complete performance of the other of the firstand second transactions; and a first account database coupled with thesettlement processor and operative to record, in a first accountassociated with the first entity, data indicative of a first positionresulting from at least the initiation of the first transaction andindicating that the first transaction is yet to be completed, the firstposition being one of a plurality of positions for which data indicativethereof is recorded in the first account as a result of at leastinitiation of performance of a plurality of other transactions receivedfrom the first entity each of which is yet to be completed, wherein eachof the plurality of other transactions is subject to subsequentcompletion between the intermediary electronic trading system and thefirst entity, each of the plurality of other transactions beingassociated with a counter-transaction matched with the other transactionby the intermediary electronic trading system.
 14. The system of claim13, further comprising: a netting processor coupled with the firstaccount database and operative to recognize the first position of theplurality of positions in the first account at least partiallycorrelates with a second position of the plurality of positions in thefirst account, the correlation being independent of them being recordedin the same account and independent of the counter-transactionassociated with the at least one transaction from which the first andsecond positions resulted; and wherein the netting processor is furtheroperative to combine the recognized first position with the secondposition to create a net position and record the net position in thefirst account and eliminate the recognized first position, the secondposition or combinations thereof, along with the associated transactionsand data indicative thereof stored in the first account database, thatare nullified by the combination; whereby fewer positions, as well asthe data indicative thereof, remain in the first account and firstaccount database for subsequent completion of the associatedtransactions.
 15. The system of claim 13, wherein the settlementprocessor is comprised by an entity different from an entity whichcomprises the request receiver, match identifier, evaluation logic andmatch processor.
 16. The system of claim 12, further comprising: acollateral processor operative to collateralize a monetized risk valueof the completed transaction and allowing the entity, from which thecompleted transaction request was received, to pledge at least a portionthereof against a margin requirement.
 17. The system of claim 12,wherein the settlement processor is further operative to substitute theintermediary for the second entity in the first transaction andsubstitute the intermediary for the first entity in the secondtransaction.
 18. The system of claim 12, wherein the first account ischaracterized by a monetized risk value representative of the at leastone position and a collateral value representative of the monetized riskvalue less any collateral value pledged as collateral, the systemfurther comprising: a second account database operative to record, in asecond account associated with the first entity, at least one positionresulting from at least one transaction related to one or more futuresinstruments; a risk processor coupled with the second account databaseand operative to compute a margin requirement for the second accountbased on the at least one position of the second account; a collateralprocessor coupled with the first account database and the risk processorand operative to receive a pledge of a portion of the collateral valueof the first account to cover the margin requirement of the secondaccount; and wherein the risk processor is further operative to reducethe collateral value of the first account and the margin requirement ofthe second account based on the pledge.
 19. The system of claim 12,wherein the particular financial instrument comprises one of a forward,spot or swap instrument.
 20. The system of claim 12, wherein the secondrequest was anonymized and routed, upon receipt, to all of the pluralityof entities, the matching further comprising anonymizing and routing thefirst request back only to the second entity.
 21. The system of claim12, wherein the second request was anonymized and routed, upon receipt,to only a subset of the plurality of entities, the matching furthercomprising anonymizing and routing the first request back only to thesecond entity.
 22. The system of claim 12, wherein the time period ofthe second request within which a suitable counter transaction will beaccepted is defined relative to a common reference.
 23. The system ofclaim 12, wherein the first request is one of a plurality of receivedrequests received by the request receiver which are determined to haveat least been transmitted prior to the expiration of the time period,the match processor being further operative to select the first requestfrom among the plurality of received requests based on criteriaspecified by the second request.
 24. A system comprising: a processorand a memory coupled therewith, the memory storing computer executableinstructions which, when executed by the processor, cause the processorto: receive, via a communications network coupled with the processor, afirst request from a first entity of a plurality of entities for a firsttransaction in a particular financial instrument; identify a secondrequest previously received via the communications network from a secondentity of the plurality of entities for a second transaction in theparticular financial instrument where the second transaction is at leastpartially counter to the first transaction, wherein the second requestis characterized by a time period within which a suitable countertransaction will be accepted; evaluate the first request to determinethe time of transmission of the first request so as to compensate forany network transmission latency of the electronic communicationsnetwork and compare the determined time of transmission with the timeperiod of the second request and further determine that the firstrequest was transmitted to the match processor prior to expiration ofthe time period regardless of whether the first request was receivedthereafter; and match the first request with the second request based onthe determination that the first request was transmitted prior to theexpiration of the time period and subsequently facilitate the first andsecond transactions without an intermediary electronic trading systemcommunicating data identifying the first and second entities to eachother.
 25. The system of claim 24, wherein the computer executableinstructions, when executed by the processor, cause the processor tofurther: initiate performance of the first transaction between the firstentity and the intermediary electronic trading system and initiateperformance of the second transaction between the second entity and theintermediary electronic trading system, wherein the settlement processoris operative to determine when one of the first and second transactionsmatched by the match processor is incapable of being completed, and,upon that occurrence, operative to complete performance of the other ofthe first and second transactions; and record, in a first account, of afirst account database, associated with the first entity, dataindicative of a first position resulting from at least the initiation ofthe first transaction and indicating that the first transaction is yetto be completed, the first position being one of a plurality ofpositions for which data indicative thereof is recorded in the firstaccount as a result of at least initiation of performance of a pluralityof other transactions received from the first entity each of which isyet to be completed, wherein each of the plurality of other transactionsis subject to subsequent completion between the intermediary electronictrading system and the first entity, each of the plurality of othertransactions being associated with a counter-transaction matched withthe other transaction by the intermediary electronic trading system. 26.The system of claim 25, wherein the computer executable instructions,when executed by the processor, cause the processor to further:recognize the first position of the plurality of positions in the firstaccount at least partially correlates with a second position of theplurality of positions in the first account, the correlation beingindependent of them being recorded in the same account and independentof the counter-transaction associated with the at least one transactionfrom which the first and second positions resulted; and combine therecognized first position with the second position to create a netposition and record the net position in the first account and eliminatethe recognized first position, the second position or combinationsthereof, along with the associated transactions and data indicativethereof stored in the first account database, that are nullified by thecombination; and whereby fewer positions, as well as the data indicativethereof, remain in the first account and first account database forsubsequent completion of the associated transactions.